- 22 - sec. 5(a), 1959-1 C.B. at 242. However, respondent argues that the discounted cashflow method should not be used where future income is unpredictable, as with HII, and “the results of such an analysis provide little, perhaps no, indication of value and should be accorded like weight.” We agree that an income-based method, such as the discounted cashflow method, is not particularly reliable where the subject company’s future income is relatively unpredictable. See Wall v. Commissioner, T.C. Memo. 2001-75; Pratt et al., Valuing Small Businesses and Professional Practices 257 (3d ed. 1998). Petitioners agree that HII’s sales and earnings are erratic and not readily predictable. Given these circumstances, we are not convinced that the value Mr. Heebink derived under the discounted cashflow method is entitled to the weight that he gave to it. However, we believe Mr. Heebink’s conclusions with respect to the discounted cashflow analysis are entitled to some consideration.22 22Mr. Engstrom gave no weight to the discounted cashflow method because small changes in certain assumptions resulted in large changes in the value of HII shares. Indeed, Mr. Engstrom opined that if HII’s expenses were increased or decreased by 1 percent of sales, it would result in a $67,000 per share increase or decrease in the value of HII shares. He also opined that a 1- percent increase in the discount rate would cause the implied value to go down by $21,000 per share; a 1-percent decrease in the discount rate would cause the implied value to go up by $26,000 per share; and a combination of a decrease in expenses by 1 percent of sales and a 1-percent decrease in the discount rate would result in the implied value to go up by about $100,000 per share. As we explain later on, we do not agree that this requires us to completely reject the discounted cashflow method (continued...)Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
Last modified: May 25, 2011